Proposal for a Recommended Practice for the Collection and Analysis of Marine Data

Proposal for a Recommended Practice for the Collection and Analysis of Marine Environmental Data

Ian Boyd¹ and Moya Crawford<sup>2

1</sup>Scottish Oceans Institute, University of St Andrews
²Deep Tek Ltd

Executive Summary

We propose the development of a Recommended Practice for the collection of data on and around man-made structures in the marine environment. The purpose of this Recommended Practice would be threefold; to achieve greater consistency and accuracy in the collection and analysis of data, so that the time and resource spent in collecting it may be used to maximum effect; to accurately quantify the impact of man-made structures and equipment on the marine environment, in order that engineers and managers should both better understand the biological conditions in which they operate and have metrics against which to quantify optimal performance and practice while having minimal environmental impact; and to provide a reliable record of ocean stewardship at both corporate and governmental level, as there are emerging legal frameworks that oblige coastal states to provide evidence of responsible governance of the ocean territories over which they have jurisdiction, The Recommended Practice would cover structures and equipment that are in use, as well as legacy objects, such as wrecks and obsolete structures.

Background

Few industrial operations in the marine environment can take place without a comprehensive pre-disturbance survey having been made. Under many regulatory regimes, the obligation to monitor impact on the marine environment continues throughout the development cycle and concludes with a post-removal survey. In addition to statutory requirements, there are voluntary programmes, such as SERPENT, in which ROV operators take photographs and record images of the marine life they observe during down-time. Much of this data, however, is unusable either because it has not been collected in a systematic way, or specific measurements are missing.

With regard to design requirements, to date many of DNV?s Offshore Standards and Recommended Practices have concentrated on life and property; the emphasis being on safety and withstanding the marine environment, be this on the surface or subsea. The impact of man-made structures and equipment on the marine environment, however, is not considered to the same extent, despite the fact that the smallest environmental footprint denotes an engineering design that is likely to be most efficient and verification of this should convey commercial advantage.

There is also a trend within Member States of the European Union to place stringent strategic control over the licenses, driven by a philosophy of zero net or long-term environmental impact. This is exemplified by the introduction of the Habitats Directive, the Marine Strategy Framework Directive, and the Environmental Liability Directive. A similar set of legislative controls that have a similar net effect are enacted in the United States and other coastal states including Canada, Australia and many in South America and the Far East are also catching up in terms of their ambitions to control the impacts of offshore industries upon the environment.

This process of increasing regulation is about more than just protection of the environment; there are at least two important additional drivers. First, the imposition of environmental standards is about legitimising claims to extending national jurisdictions to EEZs and regions of Extended Continental Shelf. Second, such regulation of environmental standards has the effect of bringing industrial activity within the legislative remit of the coastal state from a very early stage in the development cycle.


Environmental Objective of Proposed Recommended Practice

The proposed Recommended Practice would lay down the scope and procedures for consistent and reliable sampling and data collection. Its content would cover a range of structures and equipment. It would also take into account the environment in which they were situated, with a view to providing the data to assess local and far-field effects, and cumulative impact. The objective would be to provide a methodology and framework that could be interrogated by marine scientists and which was auditable by an independent third part, such as DNV. Organisations that were certified as following the proposed Recommended Practice would have the quality assurance that their data which had the benefit of being able to be taken consistently, over relatively long time periods ? was reliable. This would enable them to either prove that their activities did not have a significant or irreversible negative impact upon the environment, or make measurable improvements, either through changes in design, procedure, trade-offs, or a combination of all three.

Such initiative on the part of those operating or owning assets in the marine environment is becoming increasingly important as the definition of significant in this context is often a matter of debate, and it is clear that regulation is moving towards greater levels of precaution. For example, the precautionary principle and the polluter pays are fundamental principles residing at the heart of European environmental legislation. There is an increasing understanding of the high levels of scientific uncertainty associated with the judgements made around the definition of significant leading to greater precaution and, with this, more activities cross the boundary from benign (i.e. judge not to have a significant environment effect) to being polluting, in the sense of legislation concerning significant environmental impacts. An example of this process includes that associated with produced water. In this example regulation of the production side of the offshore oil and gas industry is moving from tolerance of discharges towards zero tolerance resulting in increasingly onerous requirements on industry to comply with legislation.

Current Standards

Because the ocean is often seen as somewhere in which there are common interests there has been a tendency for a highly diverse range of regional bodies, such as OSPAR, to develop environmental standards. However, only in areas such as chemical discharges and emissions are there currently clear and unambiguous limits defining what becomes a significant environmental effect. In other cases, such the effects upon benthic and pelagic biodiversity (both in terms of directional change and disturbance), the production of noise and the effects upon hydro- and sedimentary dynamics there are no clear standards. Moreover, the procedures for obtaining information about most of these processes are ill-defined leading to very variable standards of measurement. This presents problems in terms of making appropriate judgements about significance, it is likely to lead to drift in the objectives through the development cycle of projects and it reduced the possibility of regulators being about to examine the evidence of cumulative effects across many individually licensed industrial processes occurring within a region. This is particularly important because significant effects may be difficult to demonstrate on small project-by-project scales but may occur over much larger space and time scales.

For many decades the minimisation of impact of human activity on the environment has been seen as something of a financially intangible subject, as good stewardship added little or no value to the ?bottom line?. This is no longer the case, especially given the level of fines (and in some cases imprisonment) which states are increasingly willing to impose on ?offenders?. The case for adopting this proposed Recommended Practice should be made at board level in organisations and targeted at design engineers and onsite managers, at is only they who have the skill and knowledge to make the changes required. As DNV is trusted by both of these parts of the workforce, it is an unrivalled position to help factor in a more forward thinking and responsible approach.






Data Acquisition and Analysis

The proposed Recommended Practice would cover :

• Measurement Procedures
• Statistical and Analysis Procedures
• Reporting Procedures
  

As a first step, we suggest it may be valuable to develop guidelines and procedures around some worked examples. Such examples could include:

Standards for measuring induced underwater noise (this would be the foundation for both the guidance for mitigating the impact of seismic exploration on marine mammals and the reduction of use of DP for long term DP operations, where mooring was an option).
Standards for the survey of benthic organisms and the analysis of data.
Standards for assessment of the acoustic biomass in the water column
Standards for measuring induced electro-magnetic fields.